Persons Responsible for Implementation

Board’s Responsibilities

This Code has been developed and approved by the Board of Directors of ZIL (the “Board”). The Board shall periodically review the adequacy and appropriateness of – and compliance with – the Code. The Board shall also implement any change it believes is necessary or desirable in order to achieve Code’s purposes.

Management’s Responsibilities

The Chief Executive Officer of ZIL is responsible for ensuring that ZIL conducts its business in accordance with this Code. The Chief Executive Officer shall communicate the strong support of senior management for this Code and shall endeavor to foster a strong “culture of compliance.”